Role, as he swore it”Mr. Goldberger’s law office assistant to be directly involved only with Mr. Epstein’s case while he was serving his jail sentence at the Palm Beach County Stockade”, and “a conduit for information between the attorneys (criminal and civil) and Mr. Epstein”1
Hired16 July 2008, by Jack Goldberger, who swore to the same date and the same job description2
Role, as the plaintiffs described itEpstein’s assistant. Counsel for a plaintiff swore that Epstein’s pilot and Epstein’s house manager had both testified that Cowles worked for Epstein, and that Cowles “has represented to Jeffrey Epstein’s probation officer that he is Epstein’s assistant, not a paralegal at a law firm”3
The number in the filing”Story Cowles visited Epstein 159 times between 7/14/08 and 2/8/09, while Epstein was incarcerated in the Palm Beach County Detention facility”, cited to the corrections department’s official visitor logs3
What he actually did in the recordScheduled contractors, relayed their questions to Epstein and carried back one-word answers; sent Epstein’s movements to his federal probation officer and collected the travel permits that came back45
On his own account of himselfA curriculum vitae in his name gives paralegal posts at two West Palm Beach law firms, a licensed-realtor post at Sotheby’s International Realty, and the presidency of THE PARADISE FUND, described as a Feeder Fund to International Charities6
Where he kept an officeTHE FLORIDA SCIENCE FOUNDATION, Suite 1404. A parking-card list for the suite names four employees and he is the first of them7
Deposed⚠ The released record does not show it. His deposition was noticed for 12 May 2010; Epstein moved to stop it; the docket sheets in the release carry the motion, the response and the reply and no order on any of them89
CamerasHe asked Epstein’s approval for a contractor’s camera work and for the placement of a dock camera and a front door camera in February 2010, and in March 2010 asked about “additional camera installs”. See Epstein Video Evidence1011

Story Cowles was hired by one of Jeffrey Epstein’s criminal defence lawyers in July 2008, while Epstein was serving his Palm Beach jail sentence. For the next two years he is the figure in the released correspondence who books the workmen, puts their questions to Epstein and tells Epstein what time his probation appointment is.

Two sworn accounts of him exist in the same federal case file and they do not agree. His own affidavit and his employer’s describe a law firm employee whose entire brief was one client’s case. A plaintiff’s counsel, swearing in opposition, described a man who had visited that client in jail 159 times, who signed the jail log variously as a paralegal, an attorney and a public defender, and who told the federal probation office he was Epstein’s assistant.

Both accounts were filed within eight days of each other in April and May 2010. The released docket does not record the court resolving between them.

Where he came from

A curriculum vitae in the release, headed Story A. Cowles, sets out a Palm Beach working life before Epstein. It gives JAMES K. GREEN, P.A., a West Palm Beach firm the CV describes as handling “constitutional and crimial law”, as his employer from January 2006 to March 2008, in the post of paralegal. It gives SOTHEBY'S INTERNATIONAL REALTY, Palm Beach, part time from October 2006 to December 2007, as a licensed realtor. And it gives THE PARADISE FUND, Palm Beach, from January 2007 to April 2009, as president, the post described as “Responsible for all activities related to raising charitable funds including event planning, administration, marketing and building strong community relationships.”6

The entry that matters is the one at the top. ATTERBURY GOLDBERGER & WEISS, P.A., West Palm Beach, full time, July 2008 to “Current”, title “Paralegal and Specialized Client Relations”, and the first responsibility listed is “dealing with firm’s highest net worth client.”6 The CV never names the client. The court filings do.

The jail year

Jack Goldberger swore that he “hired Story Cowles on July 16, 2008 and he has worked for me since that time”, that he hired him “as law office assistant to be directly involved only with Mr. Epstein’s case while he was serving his jail sentence at the Palm Beach County Stockade”, and that he employed him “to be, among other things, a conduit for information between the attorneys (criminal and civil) and Mr. Epstein.”2 Cowles swore to the same three facts in the first person, and added that he “did not know, nor have any knowledge of, Mr. Epstein prior to my employment with Mr. Goldberger.”1

Counsel for a plaintiff in a related case swore to a different measurement of the same period. Citing the corrections department’s official visitor logs, filed as an exhibit, the affidavit states3:

Story Cowles visited Epstein 159 times between 7/14/08 and 2/8/09, while Epstein was incarcerated in the Palm Beach County Detention facility.

According to jail logs, Story Cowles visited Epstein in jail by stating that he was either a “Paralegal” an “Attorney” or “Public Defender.”

Through information and belief, Story Cowles is not an attorney, does not have any paralegal training and is not a Florida Licensed Paralegal.

Each of those is a numbered paragraph of that affidavit, quoted whole. They are a party’s sworn assertions in a discovery fight, not findings. The visitor logs they cite are not reproduced on this page, and the jail logs the second paragraph reads from are not cited here at all.

Two things the affidavit asserts are independently supported by other documents in the release. It states that Epstein’s pilot Larry Visoski “testified that Story Cowles actually worked with/for Mr. Epstein at the Florida Science Foundation where Mr. Cowles kept an office.”3 A parking-card list for THE FLORIDA SCIENCE FOUNDATION, Suite 1404, lists four employees, and “Cowles, Story” is the first, above “Indyke, Darren”, “Visoski, Eileen” and “Zinoviev, Igor”7. When the suite’s lease ran out in July 2009 it was Cowles whom the building manager wrote to about the move-out date, the keys and the parking cards, and Cowles who forwarded the letter to Epstein with the line “This is from out office building. / Should I ignore for now?”12 It also states that Cowles communicated with Epstein’s probation officer on Epstein’s behalf from his private e-mail3. The correspondence below is that.

Running the house

Most of what survives of him is small and practical. A contractor wants a decision, Cowles puts the decision to Epstein in one or two sentences, and Epstein answers in a word or a number.

On 6 October 2009 he wrote about the south yard: “Joe Doran received the lights and would like to come install them. He said that the job will take a full day. He has some new lights to put up and he will be taking the light fixtures out of the ground. The light fixture will be removed but the boxes and ballasts on the back wall will be left as is. Joe would like to start at 8am. I informed Joe that no workers are to be at the house before 10am. He wanted me to ask you if he could work behind the wall until 10am? He was going to come today but today did not work with our schedule.” He closed “Can Joe come at 8 or 10?” Epstein’s whole reply was “8”.4

On 10 December 2009: “Ballace Tile & Marble will not be able to finish today. They should be able to finish the scraping and grinding of the mineral deposits but will need another day to put the sealant down. It is not critical to do right away. / Should I have them hold off on this until we have another work day at the house or return tomorrow?” Epstein answered “Hold off”.13

The standing rule in the first of those, that no workers were to be at the house before ten in the morning, is Cowles’s own sentence and is the closest the correspondence comes to a statement of policy. It is also the frame for the sequence below.

Two days in February 2010

On Tuesday 16 February 2010 Cowles asked Epstein, early in the day, “Do you want me to do anything today regarding travel permits or your probation officer?”14 At 11:04 he e-mailed Probation Officer Candice Elkins under the subject “Schedule for Epstein Thursday (2/18) and Friday (2/19)”: “Officer Elkins, / Attached is Mr. Epsteins schedule for this Thursday (2/18) and Friday (2/19). Please feel free to contact me with any questions.”5

At 4:19 that afternoon he asked Epstein “Can Nick begin work again tomorrow at 10am?” At 5:11 he reported on the garden: “Randy laid the sod but is not totally finished. There are a couple low spots that he will need to fill in. Can he return tomorrow after 11? / Your depo begins at 11”.15 At 6:43 Epstein answered the first question “Yes”. Two minutes later Cowles asked “Can =ick and I have 5 minutes of your time to discuss placement of dock =amera and front door camera at your convenience tomorrow around =0:15-10:30 before you leave?” Epstein answered “Yes”.10

The following afternoon, at 2:23, Officer Elkins wrote back: “MR. COWLES, / ATTACHED IS EPSTEIN’S APPROVED TRAVEL PERMIT. / ANY QUESTIONS, PLEASE CALL ME. / THANKS, / C.ELKINS”. Cowles forwarded it to Epstein with one line: “Attached is the travel permit for tomorrow”.5 At 3:16 he asked “What time would you like Nick Lambros out of the house by?” Epstein’s entire reply was “7”.16

That is the whole of what those sheets establish: a contractor was expected, a meeting about camera placement was requested for the half hour before Epstein left, and a travel permit was obtained. None of it shows what was installed, where, or whether the meeting happened.

The contractor, and the other work he did

The contractor of 16 February is called only “Nick” on that sheet. The following day, under the subject “Nick”, Cowles gave a full name: “What time would you like Nick Lambros out of the house by?”16 On 25 March 2010 he wrote to Epstein under the subject “Scheduling new camera install”: “Nick Lambros would like to know if he can come down to do some additional camera installs late next week? For the most part he will be totally out of your way”.11 That the “Nick” of the camera thread and the Nick Lambros of the following day are one man is an inference from the dates and the subject lines; no sheet cited here states it.

Lambros appears in the release doing ordinary audio-visual work as well. On 15 June 2010 Cowles forwarded his equipment recommendations to Epstein under the subject “Projectors and TV’s”, prefacing them “This is what Stereo Nick would recommend for a new projector or new tv for master bedroom on LSJ and 6th floor for 71st St. I will add to the list:”. The recommendations are three home-theatre projectors and two flat-screen televisions, and they are signed off with a block reading “Nick Lambros / Sound X”.17

This page records that a contractor was engaged for camera work and for television and projector work at Epstein’s properties, and stops there. It makes no claim about what any camera was for, what any camera recorded, or whether any camera named in these messages was ever fitted. The administrative record of video in the Epstein investigations is at Epstein Video Evidence.

The deposition Epstein went to court to stop

A plaintiff noticed Cowles’s deposition for 12 May 2010. On 29 April, Goldberger signed and filed “EPSTEIN’S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW”. Its argument was privilege: that Cowles was a law office employee through whom attorney-client and work product material passed, that the work product privilege “extends to paralegals, investigators and legal assistants”, and that because every plaintiff’s claim rested on a period before October 2005 and Cowles was not hired until July 2008, “he has no personal knowledge of any relevant information.” It closed by arguing that the deposition was sought “for the sole purpose of harassing and intimidating him”.8

The motion also disclosed an earlier round. In October 2009 Cowles had been subpoenaed for a deposition in a companion state court case, and counsel had then agreed by telephone that he would not be deposed if another witness was produced instead, which the motion says happened in April 2010.8

The response, filed on 7 May with counsel’s sworn affidavit attached, is the source of the 159 visits and the jail-log entries. It also set out why the earlier bargain had been abandoned: the witness produced in April 2010 had, on an attorney’s instruction, taken the Fifth on “every substantive question”, so that Cowles’s testimony “may be the only non-5th amendment testimony available to Plaintiffs.”3 Epstein replied on 17 May.9

The two docket sheets in the release carry the motion at entry 536, the response at 540 and the reply at 548, and no order disposing of any of them.9 Whether Cowles was ever deposed is not shown by anything on this page.

Afterwards

He is still a reference point for Epstein in 2011. A travel agency itinerary in June 2011 is issued in the name STORY AUSTIN COWLES18, and on 20 August 2011 Epstein sent a message whose entire subject line reads “did you get what you needed from story cowles”19. When the working relationship ended, and on what terms, no document cited here says.

What the documents do not show

  • No ruling. The docket sheets in the release show the protective-order motion, the response and the reply and no order on them, and nothing cited here shows a deposition of Cowles taking place9.
  • No property. The February 2010 camera exchange names no house, no city and no room. Neither does the March 2010 message about further installs1011.
  • No recording. Nothing cited here describes what any camera was for, what any camera captured, or whether the dock camera and front door camera discussed on 16 February 2010 were ever fitted10.
  • No underlying testimony. The plaintiff’s affidavit reports what Epstein’s pilot and Epstein’s house manager testified about Cowles3; the transcripts of that testimony are not cited here and were not located in the release. The office at the Florida Science Foundation is corroborated independently7, the house manager’s account is not.
  • No agreement. The same affidavit asserts “through information and belief” that Cowles was made to sign a confidentiality agreement with Epstein3. No signed agreement is cited here, and the assertion is recorded on Janusz Banasiak at the same allegation tier.
  • No finding. Nothing cited on this page is a court’s determination about Story Cowles, and this page makes none.
  • No end date. Nothing cited here records when he stopped working for Epstein or for Goldberger.

A large part of the correspondence in his name in the release is private and personal and has nothing to do with Epstein’s affairs. None of it is reproduced, quoted or characterised here.

Footnotes

  1. AFFIDAVIT OF STORY COWLES, sworn in Palm Beach County, filed in Jane Doe No. 2 v. Jeffrey Epstein, Case No. 08-CIV-80119-MARRA/JOHNSON, S.D. Fla. EFTA00730300 p.1, a one-page printing carrying paragraphs 1 to 3 only, read at the image at 300 dpi; the sheet is clean and unredacted. The complete two-page affidavit is filed as Exhibit C to the protective-order motion at EFTA02749184 pp.9-10, where paragraphs 4 and 5 both redact the name of a person who is not named, traced or characterised on this page. ↩ ↩2

  2. AFFIDAVIT OF JACK GOLDBERGER, ESQ., same caption. EFTA00727545 p.1 of 2, read at the image at 300 dpi. Paragraphs 1 and 2 are quoted whole and in order; the sheet is unredacted. A second printing is at EFTA02749184 p.7. ↩ ↩2

  3. Affidavit of counsel for the plaintiff in related case 08-80893, sworn at Fort Lauderdale on 7 May 2010 and filed as Exhibit A to the response at DE 540-1. EFTA02749266 pp.2-4, all three read at the image at 300 dpi. The affiant’s own name is blacked out at image level in the caption and in the jurat, and is not supplied here from any other document. The quotations in this page are taken only from paragraphs that carry no redaction: 2, 4, 5, 11, 12, 13, 14, 15, and the closing words of 10 and 20. Paragraphs 3, 6, 7, 8, 9, 16 and 17 black out the names of other people; none of those paragraphs is quoted, paraphrased or summarised on this page and none of those people is identified here. This is a party’s sworn assertion in a discovery dispute, not a finding by any court. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  4. Jeffrey Epstein to story cowles, “Re: Lighting for south yard”, quoting Cowles’s message of Tuesday 6 October 2009 at 11:12 AM. EFTA01818281 p.1, read at the image at 300 dpi. The quotation is the whole body of Cowles’s message; the double space after “did not” is as printed. The image corrects the extraction in three places: the text layer renders the day as “Mc” where the sheet prints “Tue”, the time as “I I :12” where the sheet prints “11:12”, and the sender as “cowlcs” where the sheet prints “cowles”. Epstein’s reply body is the single character “8”. Cowles’s e-mail address is blacked out at image level. ↩ ↩2

  5. Story Cowles to Jeffrey Epstein, Wednesday 17 February 2010, subject “Fwd: Schedule for Epstein Thursday (2/18) and Friday (2/19)”, forwarding the reply of Probation Officer Candice Elkins timed “February 17, 2010 2:23:02 PM EST” and, below it, Cowles’s own message to Officer Elkins sent “Tuesday, February 16, 2010 11:04 AM”. EFTA02430857 p.1, read at the image at 300 dpi. Officer Elkins’s message is quoted whole and in her capitals. The image corrects the extraction in two places: the text layer prints the addressee as “story cowlcs” where the sheet prints “story cowles”, and renders a stray “a” after the officer’s name where the sheet prints a redaction bar. Every e-mail address on the sheet is blacked out and none is reproduced. A further sheet in the same series, Story Cowles to Jeffrey Epstein, Sunday 28 February 2010, reads in full: “You are going to probation tomorrow morning at 10:30am. Elkins will have both travel permits available for you to pick up” (EFTA00745993 p.1, read at the image; the sheet prints no terminal mark). On 6 July 2010 Epstein asked him “Did you forget to follow up with Elkins?”, Cowles answered “About what?”, and Epstein answered “travel permit” (EFTA01814089 p.1, read at the image; a telephone number appearing in that thread is withheld here and is not reproduced from any copy). ↩ ↩2 ↩3

  6. A curriculum vitae headed Story A. Cowles. EFTA00586666 p.1, read at the image at 300 dpi. Spelling as printed, including “crimial”. The contact block under the name is blacked out at image level and nothing from it is reproduced. The sheet is undated; its latest dated entry ends in April 2009 and its current post begins in July 2008. Five further copies are at EFTA00586667, EFTA00586770, EFTA00730302, EFTA01256137 and EFTA01300550. ↩ ↩2 ↩3

  7. PARKING CARD & DECAL LIST for THE FLORIDA SCIENCE FOUNDATION, Suite 1404. EFTA00722885 p.1 of 4, read at the image at 300 dpi. Four employees are listed and the order is as printed. The card numbers beside the names are not reproduced. The sheet carries no date. ↩ ↩2 ↩3

  8. EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW, Case 9:08-cv-80119-KAM Document 536, entered on the FLSD docket 29 April 2010, signed by Jack Alan Goldberger. EFTA02749201 pp.1-6 of 8; pp.1 and 2 read at the image at 300 dpi and the remainder read at the text layer. The quotations here are from paragraphs 2, 7, 9, 11 and 19. Paragraphs 5, 6 and 9 redact the name of a person who is not named, traced or characterised on this page, and the sentence of paragraph 6 that concerns that person is not reproduced. A second printing of the same motion is at EFTA00728104. ↩ ↩2 ↩3

  9. The docket sheet for Jane Doe No. 2 v. Jeffrey Epstein, 9:08-cv-80119-KAM. EFTA01660040 pp.35-36, read at the text layer and not at the image. Entry 536 is the motion (29 April 2010), entry 540 the response in opposition (7 May 2010) and entry 548 the reply (17 May 2010). The entries between and after them in the range this sheet covers, which runs to the end of June 2010, contain no order disposing of 536. A second docket printing at EFTA00226849 pp.90-93 carries the same three entries and likewise no order on them. This is a statement about two documents, not about the court’s file. ↩ ↩2 ↩3 ↩4

  10. Story Cowles and Jeffrey Epstein, “Re: Camera Installment”, 16 February 2010, the four messages at 4:19 PM, 6:43 PM, 6:45 PM and a fourth from Epstein. EFTA01780294 p.1, read at the image at 300 dpi; a second export carrying only the first two messages is at EFTA01780259 p.1, also read at the image. The print carries quoted-printable transmission damage and the damaged characters are left as the sheet prints them here rather than repaired: “=ick”, “=amera” and “=0:15-10:30” stand for “Nick”, “camera” and “10:15-10:30”, and the sheet also prints “=rote” for “wrote” and “=Phone” for “iPhone”. ⚠ The Sent: header on these two sheets runs five hours ahead of the times printed inside the messages, and the pair proves it: the same Epstein reply is stamped 6:43 PM inline and 11:43 PM in the header of the other copy. Any clock time given for the fourth message must say which of the two it is using. This page gives inline times only. Cowles’s e-mail address is blacked out at image level on both sheets. ↩ ↩2 ↩3 ↩4

  11. story cowles to Jeffrey Epstein, Thursday 25 March 2010 4:28:44 PM, subject “Scheduling new camera install”. EFTA02427938 p.1, read at the image at 300 dpi. The two sentences are the whole body, the sheet prints no terminal mark after “way”, and the signature below them is “Story”. The sheet is otherwise unredacted and names no property. ↩ ↩2 ↩3

  12. Story Cowles to Jeffrey Epstein, Thursday 23 July 2009, subject “Fwd: Moving Out - Florida Science Foundation - Suite 1404”, forwarding a letter from the building’s managing agent dated 23 July 2009 9:53:13 AM EDT. EFTA00772979 p.1 of 2, read at the image at 300 dpi. “out office building” is as the sheet prints it. Cowles’s own address and the managing agent’s address are blacked out at image level and are not reproduced. ↩

  13. Jeffrey Epstein to story cowles, Thursday 10 December 2009, “Re: Workers”, quoting Cowles’s message of that day at 11:18 AM. EFTA01780326 p.1, read at the image at 300 dpi. The quotation is the whole body and the image matches the extraction exactly. Epstein’s reply body is “Hold off”. ↩

  14. “Story Cowles” to “Jeffrey Epstein”, dated Tue, 16 Feb 2010 13:09:02 +0000, no subject line. EFTA00763741 p.1, read at the image at 300 dpi. The message is one sentence and is quoted whole. The time given in the body of this page is the local Eastern time; the export headers on this family of sheets run five hours ahead of the times printed inside the messages, which is demonstrable on the sheets themselves where the same message carries both. ↩

  15. Jeevacation to story cowles, “Re: Sod”, quoting Cowles’s message of Tuesday 16 February 2010 at 5:11 PM. EFTA01780273 p.1, read at the image at 300 dpi. The quotation is the whole body, the double spaces are as printed, and the sheet prints no terminal mark after “11”. Epstein’s reply body is “Yes”. A second export of the same thread, carrying a further message at 6:47 PM about a bougainvillea, is at EFTA01780299 p.1; that printing carries quoted-printable transmission damage which this one does not, so this one is cited. Cowles’s e-mail address is blacked out at image level on both. ↩

  16. Jeevacation to story cowles, “Re: Nick”, dated Wed, 17 Feb 2010 20:25:53 +0000, quoting Cowles’s message of 17 February 2010 at 3:16 PM. EFTA00710220 p.1, read at the image at 300 dpi. The quoted message is one sentence and is quoted whole; Epstein’s entire reply body is the single character “7”. Cowles’s e-mail address is blacked out at image level. Cowles’s outgoing copy of the same message is at EFTA02430017 p.1 and a duplicate of this sheet at EFTA00745547 p.1. ↩ ↩2

  17. story cowles to Jeffrey Epstein, Tuesday 15 June 2010 12:38:09 PM, subject “Projectors and TV’s”, quoting his own message of Saturday 12 June 2010 at 10:19 AM. EFTA02412439 p.1, read at the image at 300 dpi. The opening sentence is quoted whole including its trailing colon. The image corrects the extraction in at least two places: the text layer prints “httpl/www ninco.com/” where the sheet prints “http://www.runco.com/”, and “www,samsung,com” where the sheet prints “www.samsung.com”. The contractor’s signature block is as printed; the office telephone number beneath it is blacked out at image level and is not reproduced. “LSJ” and “71st St” are the sheet’s own abbreviations and are not expanded here. ↩

  18. A travel agency itinerary notice forwarded to Story Cowles, Friday 3 June 2011, subject “Fwd: Travel arrangements for STORY AUSTIN COWLES traveling on 06/03/2011”. EFTA02321972 p.1 of 3, read at the text layer and not at the image. Cited here only for the form of the name printed on the booking. A booking is not a journey, and nothing on this page says he travelled. ↩

  19. A header block for a message from Jeffrey Epstein dated Sat, 20 Aug 2011 23:57:13 +0200, surviving in the release as a quoted fragment inside a later forward. EFTA02029622 p.1, read at the image at 300 dpi. What is quoted here is the message’s Subject: line, not its body; no body is printed on the sheet, and the trailing ”—” that follows on the same line is the signature separator, not part of the subject. The recipient’s address is blacked out at image level and the recipient is not named or characterised on this page. Further printings of the same fragment, inside messages from third parties which are not quoted here, are at EFTA01775152 p.1 and EFTA02023547 p.1. ↩